Professional Documents
Culture Documents
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COMPLAINT
2.
The members of Wireless Environment are citizens of the State of Ohio and
Maryland.
11856904.1
3.
5.
7.
This is a civil action against Defendants for patent infringement arising under the
patent laws of the United States, specifically 35 U.S.C. 271 and 35 U.S.C. 281; for trademark
infringement arising under the trademark laws of the United States, specifically, 15 U.S.C.
1125; for copyright infringement under the copyright laws of the United States, specifically 17
U.S.C. 501 et seq.; for deceptive trade practices; and for unfair competition.
9.
This Court has subject matter jurisdiction over this action under 28 U.S.C. 1331,
This Court also has supplemental jurisdiction under 28 USC 1367 over state law
claims that are related to the patent, trademark and copyright claims asserted in this Complaint
and that form part of the same case or controversy as a result.
11.
because a substantial part of the events or omissions giving rise to the claims occurred in this
-211856904.1
judicial district. Based upon information and belief and as described in more detail below,
Defendants are marketing, advertising, making, using, importing, selling and offering for sale a
product that infringes Wireless Environments patent and trademark rights and copyright in this
district and that is also causing harm to Wireless Environment in this district.
12.
transacting of business in the State of Ohio and its sufficient minimum contacts with the State of
Ohio. Specifically, Defendants are subject to personal jurisdiction in this judicial district under
Ohio Rev. Code 2307.382, because, among other things, Defendants: (1) upon information and
belief, transacted business in the State of Ohio through its sale of infringing products in Ohio,
including over the internet in Ohio and worldwide; (2) have caused injury to Wireless
Environment as a result of the acts complained of herein including, but not limited to, injury in
the form of lost product sales, price erosion of Wireless Environments products, and loss of
goodwill; and (3) are causing tortious injury to Wireless Environment in Ohio by acts outside of
Ohio, namely, by regularly soliciting business, engaging in persistent courses of conduct, and
deriving substantial revenue from its sales of the infringing products in Ohio.
WIRELESS ENVIRONMENTS PRODUCTS
13.
products are lighting products marketed under its Wireless EnvironmentTM and Mr. Beams
trademarks, including the Wireless EnvironmentTM Mr. Beams MB390TM UltraBright LED
Wireless Motion Sensor Spotlight (the Wireless Environment Spotlight) and the Wireless
-311856904.1
EnvironmentTM Mr. Beams MB720TM MotionSensor LED Stick Anywhere Nightlight (the
Wireless Environment Nightlight), both of which are depicted below:
f
4e
Wireless Environment
Spotlight
Wireless Environment
Nightlight
The Design Patent, entitled Spotlight, was issued May 19, 2015, and covers an
A true and accurate copy of the Design Patent is attached hereto as Exhibit A, of
19.
selling and offering for sale, an LED spotlight, the LED Spotlight with PIR Motion Detection
and Photocell (the Taotronics Spotlight), which is substantially similar and virtually identical
-411856904.1
to, and infringes the inventive, ornamental, and novel design covered by the Design Patent, as
illustrated below:
Fig
F. 3
Fin. 2
Fig_ 4
Ft. 7
20.
offering for sale the infringing Taotronics Spotlight throughout the United States, and in other
jurisdictions worldwide over the internet.
-511856904.1
21.
gives, the patented design of the Design Patent and the design of the Taotronics Spotlight are
substantially the same and virtually identical, so as to deceive and induce the observer into
purchasing the Taotronics Spotlight, under the mistaken belief that it is the Wireless
Environment Spotlight.
22.
Viewed as a whole, consumers are confusing the product design of the Taotronics
Spotlight and the product design of the Wireless Environment Spotlight, both of which are
illustrated below:
Wireless
Environment
Spotlight
23.
Taotronics
Spotlight
obtained secondary meaning and consumers associate its unique, distinctive product design with
Wireless Environment.
24.
Among other reasons why the Wireless Environment Spotlights design obtained
secondary meaning, Wireless Environment has invested significant marketing and advertising
resources in connection with that product, which is featured on numerous websites, in catalogs
that are in circulation in over 70 million homes, and on Shop HQ, which has a viewership in
excess of 15 million households.
-611856904.1
25.
Among other reasons the design of the Wireless Environment Spotlight obtained
secondary meaning, Wireless Environment has enjoyed significant sales of that product
throughout the United States, as well as in Europe and in Asia.
26.
prior to Defendants sale of the Taotronics Spotlight, and, as a result, has priority over the
design.
27.
The substantial similarities between the design of the Taotronics Spotlight and the
design of the Wireless Environment Spotlight are causing consumers to confuse, mistake, or to
be deceived about an affiliation, connection, or association between Defendants and Wireless
Environment and their respective products.
28.
The substantial similarities between the design of the Taotronics Spotlight and the
design of the Wireless Environment Spotlight are causing consumers to be deceived as to the
origin of the Wireless Environment Spotlight, as well as Wireless Environments sponsorship, or
approval of the Taotronics Spotlight.
29.
willful and deceptive, as the Taotronics Spotlight is intended to copy Wireless Environments
product design, causing irreparable harm to Wireless Environment and further demonstrating
acquired distinctiveness in Wireless Environments product design.
DEFENDANTS INFRINGING NIGHTLIGHT
30.
obtained secondary meaning and consumers also associate its unique, distinctive design with
Wireless Environment.
-711856904.1
31.
Among other reasons why the Wireless Environment Nightlights design obtained
secondary meaning, Wireless Environment has invested significant marketing and advertising
resources in connection with that product, which is featured on numerous websites, in catalogs
that are in circulation in over 70 million homes, and on Shop HQ, which has a viewership in
excess of 15 million households.
32.
Among other reasons the design of the Wireless Environment Nightlight obtained
secondary meaning, Wireless Environment has enjoyed significant sales of that product
throughout the United States, as well as in Europe and in Asia.
33.
Wireless
Environment
Nightlight
35.
Taotronics
Nightlight
as early as 2009, years prior to Defendants sale of the Taotronics Nightlight, and, as a result, has
priority over the design.
-811856904.1
36.
The substantial similarities between the design of the Taotronics Nightlight and
the design of the Wireless Environment Nightlight are causing consumers to confuse, mistake, or
to be deceived about an affiliation, connection, or association between Defendants and Wireless
Environment and their respective products.
37.
The substantial similarities between the design of the Taotronics Nightlight and
the design of the Wireless Environment Nightlight are causing consumers to confuse, mistake, or
to be deceived as to the origin of the Wireless Environment Nightlight, as well as Wireless
Environments sponsorship, or approval of the Taotronics Nightlight.
38.
Environment is suffering the loss of goodwill with consumers in its product design, lost sales,
price erosion of the Wireless Environment products, among other types of harm.
DEFENDANTS COPYRIGHT INFRINGEMENT
40.
include instruction guides that Wireless Environment created and authored (the Instruction
Guides) and that are attached as Exhibit B.
41.
Wireless Environment has registered the copyrights in its Instruction Guide for
the Wireless Environment Spotlight and Wireless Environment Nightlight with the U.S.
Copyright Office and has obtained registration certificates for them, effective on February 3,
2015 and that are attached as Exhibits C and D, respectively.
-911856904.1
42.
The Instruction Guides have value and have been created and produced at
The instruction guides enclosed with each of Defendants Infringing Products, the
front covers of which are attached as Exhibit E, contain exact and near-exact copies of
illustrations found in the Instruction Guides, in violation of Wireless Environments copyright
and as depicted below:
Modatiroprpm.
(i)
- 10 11856904.1
L 11N LI U
IlLstration 4
IAN :
COUNT ONE
(Infringement of U.S. Patent No. D729, 965 S)
44.
Wireless Environment hereby incorporates each and every paragraph set forth
11856904.1
46.
Defendants are infringing the Design Patent by, among other things, making,
using, importing into the United States, selling, and offering to sell, the Taotronics Spotlight,
which is virtually identical in appearance and design as the inventive, novel, and ornamental
design claimed in the Design Patent.
47.
Environment has suffered, and will continue to suffer irreparable harm, unless Defendants
infringing activities are enjoined.
48.
infringement.
49.
50.
intentional, making this an exceptional case and justifying the imposition of treble damages and
an award of reasonable attorneys fees pursuant to the provisions of 35 U.S.C. 284 and 285.
COUNT TWO
(Trade Dress Infringement)
51.
Wireless Environment hereby incorporates each and every paragraph set forth
Environments trade dress rights, namely, the distinctive product designs of the Wireless
Environment Spotlight and the Wireless Environment Nightlight.
53.
Consumers are confusing the Taotronics Spotlights design with the Wireless
Consumers are further confusing the Taotronics Nightlights design with the
Wireless Environment Nightlights design because they are virtually identical in appearance.
- 12 11856904.1
55.
consumers and the general public to erroneously believe that Wireless Environment is the origin
of, sponsors, and approves those products and that the Infringing Products are the same products
as the Wireless Environment Spotlight and the Wireless Environment Nightlight.
56.
dress in its product designs, Wireless Environment is suffering irreparable harm, including, but
not limited to, the loss of goodwill it has built with consumers through its own marketing,
advertising and sale of the Wireless Environment Spotlight and the Wireless Environment
Nightlight, among other irreparable harm.
58.
exceptional case and justifying the imposition of treble damages pursuant to 15 U.S.C. 1117.
60.
but not limited to Defendants profits, actual damages, costs, and treble damages.
COUNT THREE
(Violation of Copyright Act)
61.
Wireless Environment hereby incorporates each and every paragraph set forth
Wireless Environment Spotlight and the Wireless Environment Nightlight and the illustrations in
those Instruction Guides.
- 13 11856904.1
63.
(b)
(c)
64.
65.
rights under copyright, Wireless Environment is entitled to actual damages and additional relief
pursuant to 17 U.S.C. 504 and 17 U.S.C. 505, as applicable.
66.
Defendants conduct is causing, and unless enjoined and restrained by this Court,
will continue to cause, Wireless Environment irreparable harm, for which it has no adequate
remedy at law.
67.
injunctive relief prohibiting Defendants from further infringing its copyright and ordering that
they destroy all infringing instruction guides made in violation of Wireless Environments
copyright.
COUNT FOUR
(Violations of Ohio Deceptive Trade Practices Act)
68.
Wireless Environment hereby incorporates each and every paragraph set forth
- 14 11856904.1
69.
Through their sale of the Infringing Products with designs that are being confused
with the unique, distinctive design of the Wireless Environment Spotlight and the Wireless
Environment Nightlight, Defendants are violating Ohios Deceptive Trade Practice Act:
decisions.
71.
suffering irreparable harm to the goodwill it has built with consumers through its own marketing,
advertising and sale of its Wireless Environment Spotlight and the Wireless Environment
Nightlight, among other irreparable harm.
72.
Defendants actions.
COUNT FIVE
(Common Law Unfair Competition)
74.
Wireless Environment hereby incorporates each and every paragraph set forth
- 15 11856904.1
75.
acting with the purpose and intent to deceive consumers into believing that the Taotronics
Spotlight is the Wireless Environment Spotlight.
76.
acting with the purpose and intent to deceive consumers into believing that the Taotronics
Nightlight is the Wireless Environment Nightlight.
77.
has been damaged and will continue to be damaged unless Defendants are enjoined from
advertising and selling the Infringing Products.
79.
Defendants actions.
WHEREFORE, Wireless Environment respectfully seeks the following relief against
Defendants as follows:
As to Count I:
11856904.1
As to Count II:
As to Counts III-V:
Actual damages in an amount to be determined at trial and attorneys fees.
As to All Counts:
For all other relief as this Court may deem just and proper.
- 17 11856904.1
JURY DEMAND
Wireless Environment demands a trial by jury as to all issues so triable.
/s/: Philip R. Bautista
Philip R. Bautista (0073272)
pbautista@taftlaw.com
Michael H. Diamant (0000119)
mdiamant@taftlaw.com
Amelia J. Workman Farago (0080260)
afarago@taftlaw.com
Julie A. Crocker (0081231)
jcrocker@taftlaw.com
TAFT STETTINIUS & HOLLISTER LLP
200 Public Square, Suite 3500
Cleveland, OH 44114-2302
Phone: (216) 241-2838
Fax: (216) 241-3707
Attorneys for Plaintiff Wireless
Environment, LLC
- 18 11856904.1
EXHIBIT A
Wireless Environment
32111 Aurora Rd, #8
Solon, OH 44139
877.298.9082
www.mrbeams.com
Mounting
Base
LED Lights
Motion
Sensor
Thank you for purchasing the Mr. Beams Wireless UltraBright Spotlight. We are committed to
eliminating darkness by using the latest in lightemitting diodes (LEDs). LEDs are the most efficient and durable light sources available. We are
certain that your Wireless UltraBright Spotlight will
contribute to a safer environment and provide light
where you need it at a very reasonable cost.
ENCLOSED YOU WILL FIND:
Wireless UltraBright Spotlight
Mounting Base
3 Screws and 3 Anchors
BEFORE YOU MOUNT YOUR SPOTLIGHT
Illustration 1
Illustration 2
WARNING
Use only new alkaline D-Cell batteries
with 1.5V rating. Do not mix old and
Motion Activated Spotlight turns on automatically
new batteries. If batteries are not new,
when motion is detected.
it may cause the light to malfunction.
Auto Shut-OffSpotlight shuts off automatically
INSTALLATION INSTRUCTIONS
Illustration 3
Illustration 4
Illustration 5
Important!
NOTES: Light sensor only allows Spotlight to activate in darkness. We recommend testing in a dark room or closet. When your Spotlight
Illustration 7
Remove Mounting Base by turning thumbscrew counter-clockwise as shown in Illustration 6. Pull Mounting Base off stem of Light.
Illustration 8
Illustration 9
Illustration 10
LIMITED WARRANTY
The product you have purchased is guaranteed against defects in workmanship and materials for the period stated on the package. Warranties implied by
law are subject to the same time period limitation. Some states do not allow limitations on how long an implied warranty lasts, so this time limitation may
not apply to you. If the product fails due to a manufacturing defect during normal use, return the product and dated sales receipt to the store where purchased for replacement OR send the product and the dated sales receipt to the address above. Not Covered Batteries are not covered by this warranty.
Repair service, adjustment and calibration due to misuse, abuse or negligence are not covered by this warranty. Unauthorized service or modification to this
product or of any furnished components will void this warranty in its entirety. This warranty does not include reimbursement for inconvenience, installation,
set-up time, loss of use, postage, unauthorized service, or other products used in conjunction with, but are not supplied by, Wireless Environment.
This warranty gives you specific legal rights, and you may also have other rights which vary from state to state.
EXHIBIT B
Mr. Beams
32111 Aurora Rd #8.
Solon, OH 44139
877.298.9082
www.mrbeams.com
INSTRUCTION GUIDE
Motion-Sensor
LED
WARNING
Use only new alkaline AA-Cell batteries
with 1.5V rating. Do not mix old and
new batteries. Install batteries with
polarity in correct position.
Note that this is a strong adhesive
tape and may cause damage to paint,
wallpaper, or surface underneath if
removed.
Light takes approximately 10 seconds to
activate once batteries are inserted.
If light stays on constantly, its time to
change the batteries!
INSTALLATION INSTRUCTIONS
BEFORE YOU MOUNT YOUR SA LIGHT:
Illustration 1
Illustration 2
Illustration 4
IMPORTANT NOTES:
Please use only new alkaline AA batteries with 1.5V
Do not mix old and new batteries.
Install batteries with polarity in correct position as shown.
Stick Anywhere Night Light will activate in fairly dark spaces. Test in a dark closet or bathroom.
LIMITED WARRANTY
The product you have purchased is guaranteed against defects in workmanship and materials for the period stated on the package. Warranties implied by
law are subject to the same time period limitation. Some states do not allow limitations on how long an implied warranty lasts, so this time limitation may
not apply to you. If the product fails due to a manufacturing defect during normal use, return the product and dated sales receipt to the store where purchased for replacement OR send the product and the dated sales receipt to the address above. Not Covered Batteries are not covered by this warranty.
Repair service, adjustment and calibration due to misuse, abuse or negligence are not covered by this warranty. Unauthorized service or modification to this
product or of any furnished components will void this warranty in its entirety. This warranty does not include reimbursement for inconvenience, installation,
set-up time, loss of use, postage, unauthorized service, or other products used in conjunction with, but are not supplied by, Wireless Environment.
This warranty gives you specific legal rights, and you may also have other rights which vary from state to state.
EXHIBIT C
EXHIBIT D
EXHIBIT E
JS 44 (Rev. 12/12)
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
Cuyahoga
U.S. Government
Plaintiff
Federal Question
(U.S. Government Not a Party)
U.S. Government
Defendant
Diversity
(Indicate Citizenship of Parties in Item III)
DEF
1
Citizen or Subject of a
Foreign Country
Foreign Nation
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement
BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
OTHER STATUTES
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions
2 Removed from
State Court
Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. 271; 35 U.S.C. 281; 15 U.S.C. 1125; 17 U.S.C. 501 and 28 U.S.C. 1332.
Seeking damages and injunctive relief for patent infringement under 35 U.S.C. 271 and 35 U.S.C. 281; for trademark infringement under 15 U.S.C. 1125; for copyright
infringement under 17 U.S.C. 501 et seq. ; for deceptive trade practices; and for unfair competition.
DEMAND $
in excess of $75,000
DOCKET NUMBER
06/16/2015
AMOUNT
APPLYING IFP
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JUDGE
MAG. JUDGE
Reset
1.
2.
3.
General Civil
Administrative Review/Social Security
Habeas Corpus Death Penalty
II.
RELATED OR REFILED CASES. See LR 3.1 which provides in pertinent part: "If an action is filed or removed to this Court
and assigned to a District Judge after which it is discontinued, dismissed or remanded to a State court, and
subsequently refiled, it shall be assigned to the same Judge who received the initial case assignment without regardfor
the place of holding court in which the case was refiled. Counsel or a party without counsel shall be responsible for
bringing such cases to the attention of the Court by responding to the questions included on the Civil Cover Sheet."
This action is
If applicable, please indicate on page 1 in section VIII, the name of the Judge and case number.
III.
In accordance with Local Civil Rule 3.8, actions involving counties in the Eastern Division shall be filed at any of the
divisional offices therein. Actions involving counties in the Western Division shall be filed at the Toledo office. For the
purpose of determining the proper division, and for statistical reasons, the following information is requested.
ANSWER ONE PARAGRAPH ONLY. ANSWER PARAGRAPHS 1 THRU 3 IN ORDER. UPON FINDING WHICH
PARAGRAPH APPLIES TO YOUR CASE, ANSWER IT AND STOP.
(1)
Resident defendant. If the defendant resides in a county within this district, please set forth the name of such
county
COUNTY:
Corporation For the purpose of answering the above, a corporation is deemed to be a resident of that county in which
it has its principal place of business in that district.
Non-Resident defendant. If no defendant is a resident of a county in this district, please set forth the county
wherein the cause of action arose or the event complained of occurred.
COUNTY:
(2)
(3)
Other Cases. If no defendant is a resident of this district, or if the defendant is a corporation not having a principle
place of business within the district, and the cause of action arose or the event complained of occurred outside
this district, please set forth the county of the plaintiff's residence.
COUNTY: Cuyahoga
IV.
The Counties in the Northern District of Ohio are divided into divisions as shown below. After the county is
determined in Section III, please check the appropriate division.
EASTERN DIVISION
AKRON
CLEVELAND
YOUNGSTOWN
WESTERN DIVISION
TOLEDO
(b)
(c)
Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV.
Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V.
VI.
Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII.
Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Northern
District
Ohio
__________
District
ofof
__________
Wireless Environment, LLC
Plaintiff
v.
SUNVALLEYTEK INTERNATIONAL, INC., et al.
Defendant
)
)
)
)
)
)
)
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
; or
I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, who is
; or
; or
Other (specify):
.
My fees are $
0.00
Date:
Servers signature
Servers address
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Northern
District
Ohio
__________
District
ofof
__________
Wireless Environment, LLC
Plaintiff
v.
SUNVALLEYTEK INTERNATIONAL, INC., et al.
Defendant
)
)
)
)
)
)
)
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
; or
I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, who is
; or
; or
Other (specify):
.
My fees are $
0.00
Date:
Servers signature
Servers address
Save As...
Reset